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Save39th Petition Memo 090601a

This report alleges that because of the City's failure to follow its own rules resulted in basic statistical errors. A review of the information supplied by the City indicate that the estimated number of petition signatures submitted by the Chavez Boulevard Committee is less than the number required by City Code.

Save39th Petition Memo 090601a

1.
Web: www.save39th.com Twitter: @Save39th
Email: info@save39th.com AIM: Save39th
FROM: Eric Fruits, Ph.D.
DATE: June 1, 2009
RE: César E. Chávez Street Renaming Process: Failure to follow procedure and
inadequate number of signatures
SUMMARY
• The City has failed to follow procedures it established for validating petition signatures. A
City Auditor memo describes precisely the procedure it would follow if multiple batches of
petition signatures were submitted. When additional signatures were submitted the City did
not follow those procedures.
• Among petition signers who are not registered voters, the City has made no effort to
determine whether petition signatures belonged to legal residents of the United States of
America.
• A statistically correct method to estimate the total number of valid signatures indicates that
the estimated number of valid petition signatures (2,478) is less than the number required by
City Code (2,500).
• Given the City’s procedural errors, validation errors, and statistical errors, the only way to
determine whether a sufficient number of valid petition signatures have been submitted is to
validate all of the petition signatures submitted and to verify whether the signatures belong
to legal residents.
ANALYSIS
Portland City Code 17.93.030(C)(1) states that applicants for a street renaming must obtain a
minimum of 2,500 signatures in support of the proposal from legal residents of the City at large.1
Attached are three files from the City of Portland:2
1
Information regarding the street renaming process is available on the City of Portland website at
http://www.portlandonline.com/index.cfm?c=49742.
2
The Process Memo and the Batch 1 Memo were not made available to the public until May 29, 2009.

2.
Signature petition: Failure to follow procedure / inadequate number of signatures
June 1, 2009
Page 2 of 3
1. A memo describing the petition signature verification process dated September 22, 2008
(hereafter “Process Memo”);
2. Amended Batch 1 Verification Memo dated December 10, 2008 (hereafter, “Batch 1
Memo;” the City did not provide a copy of the memo that this one amends), and
3. Batch 2 and Final Verification Memo dated February 20, 2009 (hereafter, “Batch 2
Memo”).
The City validated signatures in two batches. Results from Batch 1 were reported on
December 10, 2008. Results from Batch 2 were reported on February 20, 2009. The City added
the Batch 1 estimates to the Batch 2 estimates (Table 1) to conclude that enough signatures
had been collected (2,021 + 620 = 2,641 > 2,500).
Table 1
Batch 1 Batch 2
A. Total submitted petition lines 2,756 1,177
B. Sample for validation 300 300
C. Number deemed valid 220 158
D. Percent deemed valid (C ÷ B) 73% 53%
E. Estimated total valid (A ! D) 2,021 620
The City did not follow its stated procedure for validating petition signatures
The Process Memo (p. 2) states:
We will conduct residency verification on one random sample from the full
population of petition sheets submitted.
…
Until the deadline, the applicant can gather and submit one additional batch of
petitions to my office. Depending upon the number needed and provided, we will
either draw a fresh sample from the entire population, or verify the new names
and addresses, and report our analysis to the City Engineer. [emphasis added]
After Batch 1, the Chávez Committee submitted petition sheets on three separate days:
January 23, 2009 (93 sheets), January 26, 2009 (7 sheets), and January 29, 2009
(1 sheet). Although the Chávez Committee submitted three additional batches of petition
sheets, the Auditors office treated them as one batch.
The plain language of the Process Memo indicates that when Batch 2 was presented,
the City would either (1) verify all the signatures in Batch 2, or (2) draw a sample from
the entire set of signatures in Batch 1 and Batch 2 combined. This indicates that for
validation purposes, the signatures are assumed to be from the same population. The
City did not do either (1) or (2). Instead—in contradiction to its own stated policies—the
City drew a new sample from Batch 2. This constitutes a critical procedural error.

3.
Signature petition: Failure to follow procedure / inadequate number of signatures
June 1, 2009
Page 3 of 3
Among petition signers who are not registered voters, the City has made no effort to
determine whether petition signatures belonged to legal residents of the United States of
America
Portland City Code 17.93.030(C)(1) states petition signatures must be from “legal residents of
the City at large” [emphasis added].
It is likely that some petition signatures belong to City residents that are not legal residents of
the United States. The City has indicated in correspondence that it did not take into account the
fact that, at the time the petition signatures were validated by the City, illegal residents of the
United States could hold valid Oregon drivers licenses, be enrolled in public schools, and/or
own property in the City of Portland.
The City’s estimate of the number of valid petition signatures is less than the number
required by City Code
The City’s procedural error has produced a potential fundamental statistics error. When the
signatures come from a common population (e.g., all petition signers), a statistically correct
method to estimate the total number of valid signatures is to combine Batch 1 and Batch 2, as
shown in Table 2 below.
Table 2
Batch 1 & 2
Combined
A. Total submitted petition lines 3,933
B. Sample for validation 600
C. Number deemed valid 378
D. Percent deemed valid (C ÷ B) 63%
E. Estimated total valid (A ! D) 2,478
The combined Batch 1 and Batch 2 results indicate that not enough signatures have
been collected (2,478 < 2,500).
Because of the numerous errors in procedure, validation, and calculation, the only way to
determine whether the number of valid petition signatures is sufficient is to validate all of the
petition signatures submitted.
ABOUT THE AUTHOR
Dr. Eric Fruits is President of Economics International Corp. and an adjunct professor at
Portland State University’s School of Urban Studies and Planning. He has taught graduate-level
courses in econometrics (the application of statistical analysis to economics issues) and has
published several peer-reviewed papers, each of which have included statistical and
econometric analysis. Dr. Fruits has provided expert opinions involving statistics to United
States federal and state courts and to an international criminal tribunal. Any opinions expressed
in this memo are solely the author’s as an individual.

4.
CITY OF Gary Blackmer, City Auditor
1221 SW 4th Ave, Room 140
PORTLAND, OREGON Portland, Oregon 97204-1900
Phone: (503) 823-4808 Fax: (503) 823-4571
www.portlandonline.com/auditor
OFFICE OF THE CITY AUDITOR E-Mail: gblackmer@ci.portland.or.us
September 22, 2008
To: Tom Potter, Mayor
Sam Adams, Commissioner
Nick Fish, Commissioner
Randy Leonard, Commissioner
Dan Saltzman, Commissioner
Linda Meng, City Attorney
Steve Townsen, City Engineer
From: Gary Blackmer, City Auditor
Subject: Auditor’s Office Verification of Street Renaming Petition Information
This memo is in response to a request by Commissioner Adams that the Auditor’s Office verify
street renaming petitions. City Code Chapter 17.93 places street renaming petitions under the
authority of the City Engineer. The City Engineer has developed the street renaming petition
sheets and application materials. According to the Code the applicant’s primary City contact is the
City Engineer and we believe that should continue to be the case throughout petition verification,
for consistency.
I have heard directly from four of the five Council members and the Chief of Staff of the other that
they agree with the following verification approach.
The methods we will use are not the same as those for initiative petitions and in many ways are less
stringent. More exacting, labor intensive verification is possible but the other rules set forth for
this process are not exacting and lack any penalties or other consequences for violations. To
impose a high level of precision in petition verification would be disproportionate.
City Code Chapter 17.93 requires a street renaming applicant to obtain a minimum of 2,500
signatures in support of the proposal from legal residents of the City at large or signatures of at
least 75% of the abutting property owners along the street proposed for renaming on the petition
forms supplied by the City Engineer. We understand that the two current street renaming
applicants will likely pursue the 2,500 at-large signatures.
The two petitioners have been told by the City that it will accept signatures from residents who are
16 or older. There is no database that contains all the names and addresses for this population. The
five databases available to us are the property tax roll, voter registrations, Department of Motor
Vehicle records, and verification of school district enrollment for David Douglas and Portland
Public Schools. (We are awaiting a decision from Parkrose.) Age is not available in all these
databases. Further, signatures cannot be consistently verified because these databases do not have
them or make them available to us.

5.
! Page 2 September 22, 2008
Steps of Signature Count
1. Verification that every petition sheet has the correct street(s) to be renamed – reject any
petition sheets with street(s) that do not match the street renaming application.
2. Random sampling of 300 signatures. We will conduct residency verification on one random
sample from the full population of petition sheets submitted
3. Initial screening of the sample – examine each name and address of the sample for:
quot; Legibility – reject illegible names or addresses
quot; Location – using PortlandMaps to reject addresses outside Portland
quot; Duplicates – one of the duplicates will be rejected
4. Reject if the remaining names and addresses do not appear on any of the following data
sources:
quot; PortlandMaps
quot; Voter Registration data
quot; DMV Records
quot; school district enrollment records
5. Calculate the valid signatures – the percent of verified signers will be calculated and applied to
the total number of submitted signers to determine whether 2,500 have been submitted. The
sample size would provide 95% confidence in the sample with a precision of 4 to 5%.
6. Report to the City Engineer the results of our analysis. The Auditor’s Office will complete the
verification process within thirty calendar days from receipt of the street renaming petition
sheets.
7. Until the deadline, the applicant can gather and submit one additional batch of petitions to my
office. Depending upon the number needed and provided, we will either draw a fresh sample
from the entire population, or verify the new names and addresses, and report our analysis to
the City Engineer.
Issues to Note
We will be fair and consistent in our application of these procedures and how we address any
unanticipated situations. However, the non-specific language in the City Code, combined with the
inherent difficulties in any petition verification activity, create risks that need to be noted for these
petitions and those in the future. City Council, the City Engineer, and the consultant hired to
review the process should understand that:
quot; Some eligible signers will not be matched with any database, such as adults who recently
moved from outside Portland and have not updated their voter registration or driver’s license
information.
quot; The Auditor’s Office will review the petition sheets in a cursory manner for any obvious
forgeries but cannot provide any assurance that a person is actually the signer of the petition.
quot; The databases provide some record of residency but cannot provide any assurance that a person
is actually a resident of Portland.
quot; There is no appeal process to the Auditor’s Office for the petition verification decisions or
results produced.

7.
! Page 2 December 10, 2008
SUMMARY OF REJECTED SIGNATURES
Not in PortlandMaps, DMV, Voter Roll, School Records 39
Outside of City of Portland 25
No first or last name 10
Insufficient Address 3
Illegible name 1
Same handwriting as other records 1
Duplicate in sample 1
Total Rejected Signatures 80
Per the 9/22/2008 memo to Council, the Auditor will process one additional batch for this
street renaming petition. The second batch will be processed using the same methodology
as the first, and the Auditor will have 30 calendar days after receipt of petition sheets to
complete the verification. Depending on the number of signatures submitted for the
second batch, the random sample size may be less than 300. The final number of valid
signatures will be the sum of the calculated total signatures from the first batch plus the
calculated total signatures from the second batch.
Please let me know if you have any questions.

8.
CITY OF Gary Blackmer, City Auditor
1221 SW 4th Ave, Room 140
PORTLAND, OREGON Portland, Oregon 97204-1900
Phone: (503) 823-3546 Fax: (503) 823-4571
www.portlandonline.com/auditor
OFFICE OF THE CITY AUDITOR E-Mail: Andrew.Carlstrom@ci.portland.or.us
MEMORANDUM VIA EMAIL
To: Kurt Krueger, Bureau of Transportation
From: Andrew Carlstrom, City Elections Officer
Date: February 20, 2009
CC: Marta Guembes, César E. Chávez Boulevard Committee
Re: Final Results of Street Renaming Petition Verification
After completion of residency verification of the second batch of signatures
submitted by the César E. Chávez Boulevard Committee, the total number of
accepted signatures is 2,641.
Total valid signatures, Batch 1 2,021
Total valid signatures, Batch 2 620
Total valid signatures, Batch 1 + Bath 2 2,641
Required Number of signatures: 2,500
VERIFICATION RESULTS – BATCH 2
In January 2009, a total of 101 petition sheets containing 1,177 completed lines were
submitted to the Auditor by the César E. Chávez Boulevard Committee. On 1/23/2009, the
César E. Chávez Boulevard Committee submitted 93 completed street renaming petition
sheets to the Auditor. Seven additional sheets were submitted on 1/26/2009, and a final
sheet was submitted on 1/29/2009. Per the 9/22/2008 memo to City Council, the Auditor
has conducted verification of residency within 30 calendar days using the methodology
described in the memo. Records were verified against tax records (PortlandMaps), DMV
records, and the voter roll. School district records were not used for the second batch, as
the total number of verified signatures had exceeded 2,500 after verification against the
three other sources.
Total submitted completed petition lines 1,177
Random sample: 300
Verified valid sampled records: 158
Success rate (%): 52.67% (47.33% rejected)
Calculated total signatures 158 x (1,177/300) = 620 valid signatures

9.
! Page 2 February 20, 2009
SUMMARY OF ACCEPTED SIGNATURES – BATCH 2
Valid Records from PortlandMaps, DMV, Voter Roll: 158
Valid Records from School Records 0*
Total Accepted Signatures 158
*School Records not used for Batch 2 verification
SUMMARY OF REJECTED SIGNATURES – BATCH 2
Not in PortlandMaps, DMV, Voter Roll, School Records 102
Insufficient Address 22
Outside of City of Portland 7
No first or last name 7
Duplicates in sample 3
Illegible name 1
Total Rejected Signatures 142
The Auditor has completed timely residency verification on two batches of street renaming
petition signatures as described in the 9/22/2008 memo to Council.
Please let me know if you have any questions.